The Technical Program will consist of 1.5 days of panel sessions, Friday August 29 and Saturday August 30, 2008.

Friday, August 29, 2008
10:00 – 10:30	Arrival and registration
10:30 – 10:45	Opening
10:45 – 12:15	Recent Developments in the United States
	Recent Developments and Hot Issues in the United States Regulations addressing the generation of foreign tax credits through structured passive investment arrangements, proposed regulations re taxes on combined/consolidated income regimes, proposed regulations addressing contract manufacturing, FIRPTA treatment of swaps of real property including impact of recent ruling, and liquidating distributions by REITs to foreign persons including pension funds and governments.
	Moderator:	+ Andrew P. Solomon, Sullivan & Cromwell LLP, New York, NY, and London, UK Andrew Solomon is the Managing Partner of Sullivan & Cromwell's Tax Group and coordinates the Firm’s tax practice worldwide. A partner since 1992, Mr. Solomon has a broad-based practice, involving both tax planning and dispute resolution. Mr. Solomon has been active in structuring acquisitions, divestitures (including spin-offs) and joint ventures, especially cross-border transactions. Considered by Chambers and other rating services as one of the leading lawyers in the tax field, he is highly regarded for the quality of his advice on the taxation of complex financial products and transactions. Mr. Solomon has extensive experience advising financial institutions, with a deep understanding of the insurance industry. He is also quite familiar with the particular issues affecting private equity and hedge funds, technology and other companies that license intellectual property, and natural resource companies (including both mining and oil and gas companies). In addition to those listed below, clients he has advised recently include American International Group (AIG), Allianz, Barclays Bank, HBOS plc, IMS Health, IPC Holdings, Lightyear Capital, Philips Electronics, Standard Chartered Bank, Thomson, and Total. -------------------------------------------
	Panelists:	James Croker, Alston & Bird Marc Teitelbaum, Sonnenschein Nath & Rosenthal Brainard (Skip) Patton, Boston University School of Law
12:15 – 14:00	Lunch
14:00 – 15:30	Recent Developments in the Netherlands
	Pitfalls and opportunities with the participation exemption, anti-base erosion rules, including earnings stripping, compensation of private equity managers, recent case law of interest, transfer pricing and arbitration
	Moderator:	+ Maarten van der Weijden, Loyens & Loeff, Amsterdam Maarten J.M. van der Weijden (1963), tax lawyer, is a member of the Tax practice group. He advises clients on Dutch corporate tax, in cases of international structuring and restructuring, financial products and structured finance products. Maarten is a member of the Netherlands Association of Tax Advisers (NOB) and the International Fiscal Association (IFA). -------------------------------------------
	Panelists:	+ Monique van Herksen, Baker & McKenzie, Amsterdam Monique van Herksen heads Baker & McKenzie’s European Transfer Pricing Team and serves on the Firm’s Global Transfer Pricing Steering Committee. She assists clients in developing innovative transfer pricing solutions for their industries and with audit defense and dispute resolution. She lectures at Leiden University International Tax LL.M. program since its inception in 1998. She has presented papers and issues in her field of expertise to Governmental organizations such as the OECD and EU, including consecutive EU Fiscalis Program projects since 2005 to provide internal training to EU Member States on TP issues. She serves as a reporter for The Netherlands for the 2007 IFA seminar on TP and intangibles. Listed in the Guide to the World’s Leading Transfer Pricing Advisors since 1999, listed in International Tax Review's World Tax 2004 and World Tax 2005 Expert Guides as leading individual in tax and in Legal Media Group’s Best of the Best 2005 and 2007 Legal Practitioners guide. In 2005, 2006 and 2007 Monique van Herksen’s team has received the ITR Award for Best Transfer Pricing Team of The Netherlands. ------------------------------------------- Hans Galavazi, Freshfields Bruckhaus Deringer + Cees-Frans Greeven, Buren van Velzen Guelen After obtaining a degree in tax law and a master’s in Dutch law from Tilburg University (1988-1994) Cees-Frans has been working as a tax lawyer. He took a post-graduate course in European Fiscal Studies at Rotterdam Erasmus University (1999). Cees-Frans is a member of the Dutch Bar Association and the Dutch Association of Tax Advisors. He is the chairman of the Dutch Chapter of the European American Tax Institute and serves also on the Tax Committee of the IBA, IFA and Tax Science Association. He publishes regularly in several journals and is a frequent speaker at fiscal seminars. Lecturer in International Corporate Tax at the Hague University of Professional Education. Cees-Frans works primarily in the international tax practice and the national corporation tax practice on the structuring of investment funds, private equity and tax planning. He advises a large number of multinationals and listed companies and is regularly involved in the development of tax driven products. Recent transactions included the private placement of shares in an East European transport company as well as the flotation of a tyre group of companies. -------------------------------------------
15:30 – 16:00	Refreshment Break
16:00 – 17:30	Tax Credit vs. Exemption
	Issues and developments in the exemption versus credit debate, validity of territorial system under EC law, and changes to the indirect credit for nonqualifying participations in the Netherlands
	Moderator:	Allison Christians, University of Wisconsin School of Law
	Panelists:	+ Freek Snel, Houthoff Buruma NV, Amsterdam Freek Snel started his career as tax advisor with Loyens & Volkmaars in 1994. He holds currently a position as counsel - tax lawyer with Houthoff Buruma in Amsterdam. His practice focuses on international tax planning, especially investment funds and Spain & Portugal. Freek Snel holds a degree in law (1991) and tax law (1994) from Maastricht University. He gained a PhD in law from the University of Amsterdam after defending his thesis "Van Moeders en Dochters" on systems to prevent accumulation of taxation in parent subsidiary relationships in 2005. He is a regular lecturer and author. His English publications include "Systems to Prevent Accumulation in Parent Subsidiary Relationships", Intertax 2005-11 and "Bosal Holding Case – Landmark or Business as Usual?", European Taxation 2003-11. ------------------------------------------- Marjorie Rollinson, Ernst & Young Alan Fischl, PricewaterhouseCoopers
19:30 – 23:00	Dinner in the Kurhaus
Saturday, August 30, 2008
9:00 – 10:30	Relevant EC and tax treaty developments
	EC case law on EC Treaty Freedoms, communications by the European Commission, CCCTB, the EC version of formulary apportionment, international case law on PE’s and beneficial ownership with wider implications, including Morgan Stanley (India), Prévost (Canada), Bank of Scotland (France)
	Moderator:	+ Dennis Weber, Loyens & Loeff Dennis Weber (1970) is a Professor of European Corporate Tax Law at the University of Amsterdam (UvA). He is in charge of the international and European tax legislation research that has been accommodated at the Amsterdam Center for International Law (ACIL) of the UvA. As a visiting Professor, he is a lecturer in the European Tax Studies-course at the Erasmus University Rotterdam, at the Free University of Amsterdam (Vrije Universiteit van Amsterdam) and at the International Tax Center of Leiden (LL.M Program in International Taxation) and has been invited to lecture in 2008 at the Sorbonne University in Paris (European tax law) and in 2010 at the Wirtschaft Universität Wien in Vienna. He is affiliated to Loyens & Loeff as of counsel, where he is in charge of the European tax law team. As part of his duties, he is involved in numerous proceedings in the field of European tax law for Dutch courts and the European Court of Justice (such as Verkooijen and the D-case), and acts consultant, mainly to multinational organisations. Weber is the author of a book entitled ‘Tax avoidance and the EC treaty freedoms’ (2005), and has published more than 35 articles on European tax law in national and international professional journals, such as the Weekblad Fiscaal Recht (Tax Law Weekly), FED Fiscaal weekblad (FED Tax Weekly), European Taxation, EC Tax Review and Intertax. He has also published more than 150 tax columns in various Dutch newspapers. Weber is coordinator of the International and European Tax Law program of the Nederlandse Orde van Belastingadviseurs (Netherlands Association of Tax Lawyers: NOB), a board member of the NOB’s European tax law section, and a member of the European Tax Law Group, an independent group of tax lawyers who focus on European tax law. Weber is a deputy judge at the Den Bosch Court of Appeal, where he is primarily involved in cases related to European tax law. -------------------------------------------
	Panelists:	+ Hans Pijl, Deloitte & Touche Hans joined Deloitte as a partner in 2002, previously being a partner with Andersen’s. Besides serving a large number of multinational clients, he is responsible for Deloitte’s Dutch opinion practice. He is also a part-time judge at the Tax Court of Appeals in The Hague, and is the non-governmental expert in the UN sub-Group of Experts for the definition of the PE-Article. Hans teaches international tax law at the International Tax Center Leiden, at the Vienna University of Economics and Business Administration, and at IBFD in Amsterdam. His subjects include permanent establishments, attribution of profits to PEs, exchange of information, mutual agreement, and the interaction of public international law and taxation (sea law, human rights), and transfer pricing. Hans studied fiscal law with cum laude and linguistics at the University of Leiden, and worked for the Dutch Revenue Service and the Ministry of Finance (taxation in the oil and gas industry, fraud cases and the development of the government’s system for the avoidance of double taxation). Hans is a regular speaker and his articles on international tax can be found anywhere. He was the Dutch reporter at IFA congress in Kyoto 2007. ------------------------------------------- additional panelists TBA
10:30 – 11:00	Refreshment Break
11:00 – 12:30	Strategic M&A from Start to Finish
	Structuring the acquisition (IP buy-in issues, getting the financing right, etc.), earnings repatriation, FIN 48 and FIN 141(R) implications, and post-acquisition restructuring
	Moderator:	Peter Blessing, Shearman & Sterling
	Panelists:	Jean-Paul van den Berg, Stibbe Kimberly Blanchard, Weil, Gotshal & Manges Peter Canellos, Wachtell, Lipton, Rosen & Katz
12:30 – 12:45	Close of Meeting
12:45 – 14:00	Lunch